In the case of Madhu Bala v. Suresh Kumar (1997), the Supreme Court of India held that:

a police officer, incharge of the police station is bound to register an FIR in respect of a cognizable offence

a police officer when faced with a dilemma with respect to a complaint alleging commission of cognizable and non-cognizable offence must register an FIR

whenever a magistrate directs an investigation on a complaint, the police has to register a cognizable case on that complaint treating the same as the FIR and investigate into the same

a police officer must investigate a complaint alleging commission of a cognizable and non-cognizable offence only after a direction is issued by the magistrate